Brickell Condo Financing: What Fannie Mae Full Review Means in 2026
"It feels like you're having your wisdom teeth pulled out." That is how Melissa Cohn, regional vice president of William Raveis Mortgage in South Florida, described arranging condo loans in the weeks after August 3, 2026. She told The Real Deal in September that deals are still closing, but "the question is the pricing."
For anyone comparing Brickell with other Miami submarkets, the quote describes a real problem. Two condos with similar views, floor plans and asking prices can now lead to very different closings. One gets a conventional mortgage at standard terms. The other needs a cash buyer or a higher-rate alternative loan. The difference comes from the building's budget, its reserves and its legal disputes. The unit's finishes have nothing to do with it.
Fannie Mae and Freddie Mac announced matching changes on March 18, 2026. The biggest one took effect on August 3. Fannie retired its Limited Review process and Freddie ended Streamlined Review. These were the shortcuts that let lenders approve conventional mortgages without a deep look at an association's finances. Every conventional condo loan now goes through Full Review unless the project qualifies for a waiver. The waiver generally covers projects of 10 units or fewer, which leaves out the towers that make up most Brickell inventory.
The Real Deal reported that 40% of condos nationwide used the limited process last year. Many purchases that used to get a light check now get a close look at the association's books.
| Date | What applies | Source |
|---|---|---|
| Sept. 30, 2025 | Freddie Mac treats condo projects undergoing termination or insolvency as ineligible, including projects otherwise exempt from review | Freddie Mac Bulletin 2025-9 |
| March 18, 2026 | Fannie Mae and Freddie Mac announce aligned project and insurance changes | Fannie Mae LL-2026-03, Freddie Mac Bulletin 2026-C |
| Aug. 3, 2026 | Limited and Streamlined Review retired; reserve studies must use the highest recommended allocation; baseline funding no longer accepted | Fannie Mae LL-2026-03 |
| Jan. 4, 2027 | Minimum replacement reserve contribution rises from 10% to 15% of budgeted assessment income for Full Review loans | Fannie Mae LL-2026-03, Freddie Mac Bulletin 2026-C |
The January date falls right after condo budget season. Budgets that boards adopt this fall will be tested against the 15% minimum on Full Review loan applications dated January 4, 2027 or later. Cohn told The Real Deal that "a lot of these buildings don't have the financial capacity to increase their reserves to 15 percent."
The headlines describe the change as tighter lending, and in most of the country that is accurate. Florida is different. Since 2008, Fannie Mae had a Florida-only restriction that held Limited Review loans to 75% loan-to-value, compared with 90% in other states. Mortgage Professional America reported in June 2025 that Florida condos approved under Full Review already allowed borrowers to go to between 95% and 97% LTV. Danielle Blake, chief of residential and advocacy at the Miami Association of Realtors, told the publication that the association had asked Fannie "many times, many different ways" why Florida was singled out.
Fannie's March letter says that retiring Limited Review "effectively retires the remaining geographic restrictions that apply to the state of Florida." In Brickell, the change cuts both ways. A building with healthy reserves, clean insurance and no critical repairs now goes through the same Full Review as a building in any other state, without the old Florida-only cap. A building that relied on the lighter review now has its finances examined directly. The rule split the market by building quality. Cohn put it this way: the changes "will put a premium on the value of the buildings that are compliant."
Most buyers miss this part. Florida's 2025 condo law, HB 913, took effect July 1, 2025, and gave associations more flexibility. A Structural Integrity Reserve Study must include a baseline funding plan that keeps the reserve cash balance above zero. After a completed milestone inspection, an association can pause or reduce reserve contributions for up to two consecutive annual budgets, with a majority vote, so it can put money toward the inspection's repair recommendations. It must complete a new SIRS before contributions resume. According to Becker's summary of the law, the pause applies to budgets adopted by December 31, 2028.
The lender rules move the other way. For loan applications dated on or after August 3, 2026, a lender that relies on a reserve study must confirm the budget includes the study's highest recommended reserve allocation. Lenders can no longer accept the baseline method, which Fannie describes as allowing the reserve cash balance to "approach but never fall below zero."
So a Brickell association can fund reserves exactly as Florida law allows and still have its budget fail a lender's Full Review. The Felten Property Assessment Team, a Florida reserve-study firm, warned boards about this in April 2026. Choosing the state-approved minimum, it wrote, "could make it impossible for your owners to sell their units to buyers using traditional mortgages." Neither law nor lender rule makes a failure automatic. The risk depends on which funding path a board picks.
Rules like these matter in proportion to how many buyers borrow. MIAMI REALTORS' August 2026 figures for ZIP 33131, which covers Brickell and Brickell Key, show cash purchases at 49% of condo and townhome sales. In 33133, which covers Coconut Grove, the cash share was 83%. About half of recent Brickell buyers used financing, so lender standards affect a large share of the people who might buy a given unit.
The same August 2026 table shows how much leverage buyers have. In 33131, the median condo and townhome price was $655,000, down 6.4% year over year. Months' supply stood at 18, the median time to contract was 116 days, and sellers received a median 93% of original list price. With 18 months of supply, a buyer can pass on a unit in a building that is hard to finance and choose another one. Those ZIP figures mix every building age and type. Even so, a market with this much supply makes buyers compare buildings closely.
Lender scrutiny was already rising before August. The Miami Herald, citing a count from Allcock Marcus, reported 344 Miami-Dade buildings on Fannie Mae's unavailable list as of March 2025, up from 113 in May 2023. That count is now more than 18 months old, and Fannie does not publish the list. Fannie's status tool is limited to associations, management companies and their authorized advisers, so a buyer usually learns a building's status through the HOA or the lender.
None of these buildings has been publicly reported as ineligible for Fannie Mae or Freddie Mac financing. They show the kinds of costs and disputes a Full Review examines.
Brickell Key has about 11 condo buildings, each with its own association, plus a master association. On May 22, 2026, five associations filed suit in Miami-Dade Circuit Court over a $32.3 million master-association assessment for seawall and baywalk work tied to the Brickell Key Shoreline Resiliency Initiative. The five were Brickell Key One, Brickell Key Two, Isola, Courvoisier Courts and Carbonell. The Real Deal reported that the complaint argues the owners should not pay for property they do not own. Swire Properties said it had not been served, and that it and the master association "have always complied with all laws." An October 2025 report, based on an earlier $42 million project estimate, gave example contributions of $3,581 to $5,565 for a 600-square-foot unit and $14,921 to $20,319 for a 2,500-square-foot unit, depending on payment terms. The same report described a Brickell Key Two owner's separate building-repair assessment of about $47,000. On Brickell Key, a buyer has to look at two levels of assessments, and the building budget is only one of them.
The two-tower complex at 1060 Brickell Avenue was built in 2008 and has 592 units. In 2025 it faced a $21 million assessment that included $7.7 million for façade work on Tower II and $3.5 million for garage and basement work. The Real Deal reported that in late September 2025, a judge ordered the board to hand over records and control to the owners who led the recall. At that point, litigation related to the assessment was still unresolved. Fannie lists significant litigation among the reasons a project can be ineligible. Building age is not the only predictor of this kind of risk.
At the St. Louis, 800 Claughton Island Drive, a 134-unit tower completed in 1995, Related Group and Terra were negotiating a buyout this spring. Estimates put the price near $1.5 million per unit. The Real Deal reported that by May 2026, about 80% of owners had agreed to negotiate, which is the threshold the declaration requires. Since September 30, 2025, Freddie Mac has treated projects undergoing termination as ineligible. In any building where a termination becomes formal, the pool of buyers who can finance a unit gets smaller.
Brokers told The Real Deal that waiting for association documents has slowed deals, and that some are submitting conventional and non-QM applications at the same time. It helps to request these documents on the day your offer is accepted.
Does a building that fails Full Review mean no lender will finance a unit? No. Non-QM lenders still make these loans, usually at higher rates and with tighter qualifying standards.
Do new Brickell towers avoid this? Fannie retired the separate Florida PERS review for new attached-unit projects, so lenders now review them under Full Review. The presale requirement still applies: at least 50% of units must be sold or under contract to owner-occupant or second-home buyers.
Is this financial or legal advice? No. Confirm terms with your lender and review association documents with your attorney.
A conventional loan on a Brickell tower unit is now underwritten together with the association's budget, reserve study and assessment history, so we review those documents before we discuss price. If you are weighing a specific building, Ben Moss Group can go through its documents with you before you commit. Schedule a private consultation.
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